Wine E-Labels in France: The Rules for the Ingredients QR Code
Every wine produced since 8 December 2023 must give its ingredients list and nutrition declaration. Regulation (EU) 2021/2117 lets producers put both on an electronic label opened by a QR code, on three conditions: the energy value and allergens stay printed on the bottle, the page does not mix that information with commercial content, and no user data is collected or tracked.
The rest of this article is about the third condition, because it is the one ordinary QR code tools break by default, and about the checks worth running before a back-label print run in France.
What has to stay printed on the bottle?
The energy value, the allergens and every other mandatory particular stay on the physical label. Only the two particulars added in 2023, the ingredients list and the full nutrition declaration, can move behind the code.
The energy value is shown with the symbol "E", in kilojoules and kilocalories per 100 ml. Allergens, sulphites first but also egg or milk when fining leaves them in the finished wine, are printed on the bottle too. As the legal department of the Côtes-du-Rhône winegrowers' union summarised for its members in December 2023, every other particular has to stay in the same field of vision as before.
| Information | Physical label | Electronic label |
|---|---|---|
| Energy value (E, kJ and kcal per 100 ml) | Mandatory | Repeated in the full table |
| Allergens (sulphites, egg, milk) | Mandatory | Repeated in the ingredients list |
| Ingredients list | Optional if a code is used | Mandatory if not printed |
| Full nutrition declaration | Optional (energy alone is enough) | Mandatory if not printed |
| Wording saying what the code contains | Mandatory, next to the code | Not applicable |
| Other mandatory wine particulars | Mandatory, unchanged | Cannot be moved there |
The full declaration follows the usual food order: energy, fat with saturates, carbohydrate with sugars, protein and salt, preferably as a table.
For ingredients, you list the grapes, any sugar and rectified concentrated must used, the tirage and dosage liqueurs, and the additives still present in the finished product: acidity regulators, preservatives and antioxidants, stabilising agents, packaging gases. Processing aids such as fining agents are not listed unless they are allergens.
Is the word "ingredients" next to the code mandatory?
Yes, on the European Commission's reading: a generic symbol such as an "i" is not enough. The code needs wording that says what it contains, for example "Ingredients and nutrition declaration" or "Ingredients / Nutrition", in French on a bottle sold in France.
That position is in Commission notice C/2023/1190, published in the Official Journal on 24 November 2023 as a set of questions and answers. It is not binding, but it is the reading enforcement authorities received, and in France wine labelling is checked by the DGCCRF, the consumer protection and fraud authority. The DGCCRF published an application guide in 2024 on the ingredients list and nutrition declaration for wines, with sample labels.
One more recent fact is worth tracking. Regulation (EU) 2026/471, applicable since 18 March 2026, authorises the Commission to adopt new rules on the electronic labelling of wine ingredients and nutrition information. Until an act is adopted on that basis, the 2023 reading remains the practical reference, and an "i" on its own remains a risk.
Why is a code with scan analytics the wrong tool here?
Because the condition is explicit: no user data may be collected or tracked on the path to the electronic label. A code that records the time, device and city of every scan does exactly what the rule excludes.
It is worth saying plainly, since this is our trade. The codes we produce are dynamic codes: they go through a redirect that counts scans, which is their whole point on a poster, a menu or a business card. Between a bottle and its ingredients list, that point becomes a defect. The ingredients code should contain the page address directly, like a static code, and the page should load no advertising tracker and no audience measurement tool. If it shows a cookie consent banner, it is loading something that has no business there.
Separation from commercial content is the other half of the rule. The ingredients page shows no shop, no promotion and no newsletter sign-up. Specialist platforms have built this in: U-label, developed by CEEV and spiritsEUROPE, provides a page without marketing content. If you host the page yourself on the estate's website, it has to stay an isolated page with no menu leading to the shop. For the wider picture of scan measurement under the GDPR, our article on scan tracking and consent covers what a redirect log actually holds.
Can a back label carry two codes?
Yes, nothing forbids it, and it is often the best answer: one code for ingredients, with no tracking, and a second code for the commercial side, such as an estate visit, a tasting booking or the online shop.
The second code can be dynamic and measured, since it carries no mandatory information. The two must be told apart at a glance, each with its own wording, or the shopper scans at random and an inspector cannot tell which one carries the regulated information. Our guide to two codes on one label gives the spacing and margins that stop a phone from reading the wrong one.
How long does the page have to stay online?
For as long as the wine can be sold or drunk. The Commission's questions and answers ask that the electronic solution offer the same guarantees as a printed label for legibility, stability, reliability, durability and accuracy, throughout the product's life.
For this year's rosé, that is short. For a 2024 vintage built to age and opened in 2036, it is long, and the address printed on the bottle can no longer be corrected. Three practical consequences:
- An address you control. A page on your own domain survives a change of provider. A page hosted by a provider means knowing what happens to its addresses if it closes or you leave, which we cover in what happens when a generator shuts down.
- One page per wine. Composition changes from one cuvée to another and sometimes from one vintage to the next. A single electronic label for the whole range ends up wrong for part of the bottles.
- A register. For each cuvée and vintage, record the encoded address, the date it went live and the person who signed off the list. That is what an inspection will ask for.
What did the CLCV survey find in 2025?
The French consumer association CLCV published a press kit on wine labelling in September 2025, based on 148 references photographed in June 2025 in supermarkets and wine shops.
Of the 85 wines from the 2024 vintage in the sample, 96% met the labelling obligation and 90% used a QR code rather than the label. For 20% of the QR code wines, the association found at least one problem: a code that did not work, missing wording next to the code, an incorrect ingredients list, or a mismatch between bottle and page. For 11 wines the full information could not be reached, including cases where a second click was needed after an advertising page. For 10 wines the wording next to the code was incomplete.
The same kit cites a 2023 behavioural study by the Commission's Joint Research Centre: of 3,420 consumers, 4% scanned every code offered and 37% scanned none. That is an argument for taking care over the code, not for dropping it: those who scan are looking for something specific, an allergen or the sugar content, and need to find it first time.
How do you check a back label before printing?
Run this check on the printer's proof, not on the file, and repeat it for every new vintage.
- Scan with two phones, an iPhone and an Android, using the stock camera, with the proof held against a bottle. Glass curvature reduces the usable size of the code, which is where our QR code size guide helps.
- Open the page in a private window. No cookie banner, no advertising and no link to the shop should appear before the list.
- Compare the list with the technical sheet for the cuvée and vintage, additive by additive, with the function of each ("preservative: sulphites", for example).
- Check the physical label: energy value in kJ and kcal per 100 ml, allergens, and the wording next to the code, readable without a magnifier.
- Check the encoded address. It should point straight at the ingredients page, with no measuring redirect, on a domain you can keep up for the life of the wine.
- Archive a dated screenshot of the page next to the approved proof.
Frequently asked questions
Do wines produced before 8 December 2023 need a code?
No. According to the DGCCRF, wines produced and labelled before that date can be sold until stocks run out without the new particulars. What counts as "produced" was debated for the 2023 vintage, though, and some trade bodies exempted it while others did not.
Can the ingredients page be in English only?
The page can offer several languages, which helps for export, but a wine sold in France must give this information in French, as the law of 4 August 1994 on the use of the French language in product presentation requires. The simplest setup is a page that opens in French and offers other languages without changing address.
Can one code serve both the ingredients and the shop?
Not if the shop appears on the same page as the ingredients: that mix with commercial information is exactly what the rule excludes. Two separate codes, each with its own wording, avoid the question.
